Peak Hill Gold Mine Pollution Incident Response ......ALKANE RESOURCES LTD POLLUTION INCIDENT...

ALKANE RESOURCES LTD POLLUTION INCIDENT RESPONSE MANAGEMENT PLAN Peak Hill Gold Mine Revision 5

Peak Hill Gold Mine

Pollution Incident Response

Management Plan


Peak Hill Gold Mine

Pollution Incident Response Management Plan

_____________________________________________________________________________ Table of Revisions

Revision Number Revision Date Prepared By Approved By: Comments

Revision 5 Sep 2017 Michael Sutherland Nic Earner Submission for

Information


TABLE OF CONTENTS 1. INTRODUCTION AND SCOPE ....................................................................................................... 1

2. LEGAL REQUIREMENTS AND CONSULTATION ........................................................................ 3

3. DEFINITION OF A POLLUTION INCIDENT ................................................................................... 5

4. DUTY TO NOTIFY ........................................................................................................................... 5

4.1 REQUIREMENT .................................................................................................................... 5

5. INVENTORY OF POTENTIAL POLLUTANTS ............................................................................... 6

5.1 OPERATIONAL PHASE ........................................................................................................ 6

6. INVENTORY OF SAFETY EQUIPMENT......................................................................................... 7

6.1 OPERATIONAL PHASE ........................................................................................................ 7

7. INSTALLED POLLUTION CONTROL MEASURES ....................................................................... 8

8. ACTIONS TO BE TAKEN BEFORE, DURING AND IMMEDIATELY AFTER A POLLUTION INCIDENT ........................................................................................................................................ 8

8.1 ACTIONS TO MINIMISE A POLLUTION INCIDENT............................................................. 8

8.2 ACTIONS TO BE TAKEN DURING A POLLUTION INCIDENT ............................................ 8 8.2.1 Ensure personnel safety .............................................................................................. 9 8.2.2 Notification of authorities ............................................................................................. 9

8.2.2.1 Protocol ......................................................................................................... 9 8.2.3 Consultation of the MSDS ........................................................................................... 9 8.2.4 Notification of Neighbours ......................................................................................... 10

8.3 ACTIONS FOLLOWING A POLLUTION INCIDENT ........................................................... 10 8.3.1 Clean up and Recovery ............................................................................................. 10 8.3.2 Incident Report .......................................................................................................... 10

9. CONTACT DETAILS ..................................................................................................................... 10 9.1 PHGM KEY CONTACTS ..................................................................................................... 10

9.2 APPROPRIATE REGULATORY AUTHORITIES ................................................................ 10

9.3 COMMUNICATING WITH NEIGHBOURS .......................................................................... 11

10. TRAINING ...................................................................................................................................... 11

11. ACCESS TO THE PIRMP .............................................................................................................. 12

12. TESTING OF THE PIRMP ............................................................................................................. 12 APPENDIX 1 – Pollution Incident Risk Assessment APPENDIX 2 – Incident Report Template


THIS DOCUMENT IS UNCONTROLLED ONCE PRINTED PAGE 1

1. I N T RO D U C TI ON AN D S CO PE This Pollution Incident Response Management Plan (PIRMP) has been prepared as a tool so that in the event of a pollution incident, Alkane Resources Ltd (Alkane) personnel will respond in a practised, planned manner. The PIRMP will be used to manage the impact on employees, neighbours, the wider community and the environment both on and off site. The PIRMP aims to ensure comprehensive and timely communication about a pollution incident to all personnel present at Peak Hill Gold Mine (PHGM), immediate neighbours, the Environment Protection Authority (EPA) and other relevant agencies such as:

• Parkes Shire Council; • Ministry of Health; • WorkCover Authority of NSW; and • Fire and Rescue NSW.

The PIRMP also aims to minimise the risk of a pollution incident by firstly identifying the risks, putting measures in place to reduce the likelihood of an incident occurrence and finally planning and practising the response to a pollution incident. This PIRMP post-dates mine closure and decommissioning of the Peak Hill Gold Mine which operated between 1996 and 2005. The site is currently largely decommissioned and no longer carries out mining operations nor stores nor handles dangerous goods. The PIRMP does not detail the procedure for treatment of injured persons or remediation of the environment following a pollution incident. The Peak Hill Gold Mine is located immediately north and east of the township of Peak Hill. The site contains several mining leases and a gold lease. Five open cut voids are fenced and secured from the public. A Tourist Mine permit is held by Alkane and operated under an agreement with Parkes Shire Council. Lot 81 contains the final rehabilitated landforms of the waste rock emplacement (WRE) and spent heap leach material. A site house, exploration office, core yard, crib room, lab and workshop are the remnant structures from the operating mine. These are all transportable buildings but are still used by Alkane exploration personnel. Access to the site office is from Roose Road (east of Newell Highway) 1km north of Peak Hill Post Office. A location map is included as Figure 1. This shows the location of the premises to which this licence relates, the surrounding area (Peak Hill township, neighbouring farms and Newell Highway). It is important to note that there have been no chemicals, fuels or other potentially hazardous items stored on site since December 2005. There is a quantity of sulphide bearing waste rock encapsulated in an oxide waste rock emplacement which has been rehabilitated to a final landform.



. Figure 1



2. L E G AL R E QU I R EM E N TS AN D CO N S U LTAT I ON The Protection of the Environment Legislation Amendment Act 2011 introduced changes designed to improve the way pollution incidents are reported and managed in NSW. The changes apply to the holders of Environmental Protection Licences.

The requirements for PIRMP are set out in Part 5.7A of the Protection of the Environment Operations Act 1997 (POEO Act 1997) and the Protection of the Environment Operations (General) Regulation 2009. In summary these provisions require that:

• all holders of an Environment Protection Licence prepare, implement and test a PIRMP;

• the plan includes the information detailed in the POEO Act 1997 (section 153C). These requirements are reproduced in Table 1;

• the plan must be kept at the premises to which the Environment Protection Licence relates.

Table 1 – Requirements for a PIRMP, Section 153C (d) Protection of the Environment Operations

Act 1997

Clause Number Requirement Section in this Plan

98 C (1) a A description of the hazards to human health or the environment associated with the activity to which the licence relates

Appendix 1

98 C (1) b The likelihood of any such hazards occurring, including details of any conditions or events that could, or would, increase that likelihood

Appendix 1

98 C (1) c Details of the pre-emptive action to be taken to minimise or prevent any risk of harm to human health or the environment arising out of the relevant activity.

Section 7.1

98 C (1) d An inventory of potential pollutants on the premises or used to carry out the relevant activity Section 5

98 C (1) e

The maximum quantity of any pollutant that is likely to be stored or held at particular locations including underground tanks at or on the premises to which the licence relates

Section 5

98 C (1) f

A description of the safety equipment or other devices that are used to minimise the risks to human health or the environment and to contain or control a pollution incident

Section 6

98 C (1) g

The names, positions and 24 hour contact details of those key individuals who:

• Are responsible for activating the plan

• Are authorised to notify relevant Authorities under section 148 of the Act

• Are responsible for managing the response to the pollution incident.

Section 8.1




98 C (1) h Contact details of each relevant authority referred to in section 148 of the act. Section 8.2

98 C (1) i

Details of the mechanisms for providing early warnings and regular updates to the owners and occupiers of the premises in the vicinity of the premises to which the licence relates

Section 8.3

98 C (1) j The arrangements for minimising the risk of harm to any persons who are present where the scheduled activity is being undertaken

Section 7.1

98 C (1) k

A detailed map showing the location of the premises to which the licence relates, the surrounding area that is likely to be affected by a pollution incident, the location of pollutants on the premises, and the location of stormwater drains on the premises,

Figure 1 and 2

98 C (1) l

A description of how any identified risk of harm to human health will be reduced, including as a minimum, means of early warnings, updates and the action to be taken during or immediately following a pollution incident to reduce the risk,

Appendix 1 and

Section 7

98 C (1) m The nature and objectives of any staff training program in relation to the plan, Section 9

98 C (1) n The dates on which the plan has been tested and the name of the person who carried out the test, Table 11

98 C (1) o The dates on which the plan is updated, Table of Revisions

98 C (1) p The manner in which the plan is to be tested and maintained, Section 11

Other Requirements of the plan

Availability of the plan. The plan is to be available to an authorised officer on request and on the premises to which the licence relates or where the activities take place and to any person who is responsible for implementing the plan

The plan is to be made publicly available within 14 days of its preparation in a prominent location on a publicly accessible website of the person who is required to prepare the plan

Section 10

Testing of the plan is to be carried out in such a manner as to ensure information included in the plan is accurate and up to date and the plan is capable of being implemented in a workable and effective manner.

The test is to be carried out at least once every 12 months and within one month of any pollution incident

Section 11




occurring in the course of an activity to which the licence relates so as to assess, in the light of an incident, whether information included in the plan is accurate and up to date and the plan is still capable of being implemented in a workable and effective manner.

3. D E F I N I T I O N OF A P O L L U TI ON I N CI DE N T The POEO Act 1997 defines a pollution incident as:

“…pollution incident means an incident or set of circumstances during or as a consequence of which there is or is likely to be a leak, spill, or other escape or deposit of a substance, as a result of which pollution has occurred, is occurring or is likely to occur. It includes an incident or set of circumstances in which a substance has been placed or disposed of on premises, but it does not include an incident or set of circumstances involving only the emission of any noise.”

4. D U T Y TO NO TI F Y

4.1 REQUIREMENT The holder of an Environment Protection Licence is required to notify the relevant authorities if there is a risk of “material harm to the environment”.

Harm to the environment is material if:

1. It involves actual or potential harm to the health or safety of human beings or to ecosystems that is not trivial; or

2. It results in actual or potential loss of property damage of an amount or amounts in aggregate exceeding $10,000 (or such other amount as is prescribed by the regulations); and

3. Loss includes the reasonable costs and expenses that would be incurred in taking all reasonable and practicable measures to prevent, mitigate or make good harm to the environment.

Harm to the environment includes any direct or indirect alteration of the environment that has the effect of degrading the environment and, without limiting the generality of the above, includes any act or omission that results in pollution.

Licence holders are required to report pollution incidents immediately (this means without delay) to all of the appropriate regulatory authorities.

These appropriate regulatory authorities are the:

• Environment Protection Authority

• Ministry of Health

• WorkCover NSW

• Parkes Shire Council and

• Fire and Rescue NSW



Failure to notify in accordance with the Act carries a maximum penalty of $2 million. Increases to penalty notice amounts have been implemented through the POEO (General) Amendment (Fees and Penalty Notices Regulation 2014 which commenced on 29 August 2014 http://www.legislation.nsw.gov.au/sessionalview/sessional/subordleg/2014-564.pdf

5. I N VE N TO RY OF PO TE N TI AL P O L L U TAN T S The tables below provide an indicative inventory of the potential pollutants on site. These tables will be updated every four months upon the commencement of construction.

5.1 OPERATIONAL PHASE The Table below contains chemicals that were on site during operations but are no longer (since 2005) held on site. The only potentially hazardous material on the PHGM site is pyritic waste rock.

Table 2 – Inventory of potential pollutants during mining operations

Product Location Maximum Quantity

Diesel Fuel Mining Contractor Yard Nil

Lubricants Plant Workshop Nil

Sodium Cyanide Reagents Compound Nil

Sodium Hydroxide Reagents Compound Nil

Hydrochloric Acid Reagents Compound Nil

ANFO Explosives Magazine Nil

Copper Sulphate Reagents Compound Nil

LPG LPG Storage Area Nil

Hammer Oil At drill rig Nil

Anti-Freeze Mining Contractor Yard Nil

Surface water pollutants Northeast and northwest sediment ponds

Nil

Acid Mine Drainage* Waste Rock Emplacement

Heap Leach Final landform

Negligible AMD

*808,660 tonnes of pyrite rich waste rock are encapsulated in the 22.7Ha Waste Rock Emplacement. Very minor amounts of pyritic material have contaminated the oxide heap leach ore material.

http://www.legislation.nsw.gov.au/sessionalview/sessional/subordleg/2014-564.pdf



6. I N VE N TO RY OF S AF E T Y EQU I PM E N T The table below provides an inventory of the safety equipment and other devices available on site to minimise the risks to human health, the environment and to contain/control a pollution incident at PHGM.

6.1 OPERATIONAL PHASE Table 3 – Equipment available on site during mining operations to help in the event of a pollution incident

Product Location Purpose

Spill Kit Process Plant Control of minor spills

MSDS Administration Offices, workshops

Provide data on chemicals

First Aid Kits Administration Offices, vehicles

For administering first aid

Fire Extinguishers Scattered all through process plant and buildings, all vehicles

Control of any minor fire

Fire Hydrants* Fire ring main around plant Control of larger fires

Oxy-Viva* Process Plant Cyanide poisoning equipment

Emergency Shower* Process Plant For administering first aid

*These items have been decommissioned since mine closure as they are no longer required at PHGM.



7. I N S TAL L E D PO L L U TI O N CON T R O L M E AS U R E S The following measures will be used to prevent pollution to the environment when storing and handling various chemicals and substances and waste materials:

Table 4 – Pollution control measures during mining operations

8. AC T I O N S TO B E TAK E N B EF O R E, D U RI NG AN D I M M EDI AT E LY AF T E R A P O LL U T I O N I N CI DE N T

8.1 ACTIONS TO MINIMISE A POLLUTION INCIDENT The following actions have been undertaken or are ongoing and aim to minimise an event from which a pollution incident may result:

• A Pollution Incident Risk Assessment has been undertaken and is included in Appendix 1. This assessment allows Alkane to identify the risks associated with activity, put management measures in place to reduce the likelihood of any significant risks occurring and therefore minimise the likelihood of a pollution incident.

• Regular inspection of the integrity of waste rock emplacement and monitoring of the surface water that sheds from this landform will indicate whether there is potential for an environmental incident

• A consultant has been engaged to monitor landscape function analysis (six monthly) which will provide a measure of landform stability and potential outbreak of Acid Mine Drainage.

• In addition to this PIRMP, the mine site is inspected at least annually by staff of DRE and EPA though an MREMP inspection.

8.2 ACTIONS TO BE TAKEN DURING A POLLUTION INCIDENT Given the fact the mine is in a closure phase a major pollution incident on site is extremely unlikely. In the event of a pollution incident the following actions will be taken:

• Ensure personnel safety. Assess the necessity for evacuation. If evacuation is required then evacuation will be undertaken in accordance with TGO Evacuation Procedure. A bushfire would be the most likely scenario requiring an evacuation. (Acid Mine Drainage is a relatively slow threat to the environment).

• Undertake emergency response other than evacuation.

• Contact the Appropriate Regulatory Authorities (ARA).

• Take direction from ARA if provided.

• If safe and possible to do so, undertake immediate measures to prevent further impacts from the pollution incident.

Product Storage Facility

Acid Mine Drainage Encapsulation of sulphidic material within an 80% by volume oxide waste rock emplacement. Northeast Sediment Pond captures surface

waters flowing from WRE.

Lime (CaCO3) Purchased and imported to site on an as needs basis

Surface water pollutants Northeast and northwest sediment ponds (Licenced discharge points)



• If required seek assistance from specialist consultants/contractors.

These actions are discussed in more detail below.

8.2.1 Ensure personnel safety If a pollution incident occurs the first priority is to ensure personnel safety, visually assess the situation and if there is significant risk to human health, undertake proceedings to evacuate the site.

If evacuation is not required the area shall be isolated and segregated to prevent personnel coming in contact with the incident. Barriers are to be erected, and other isolation measures implemented where available. If possible to isolate any release by turning off valves safely, this should be carried out. The area supervisor is to be informed so that senior management can also be advised.

Two-way radio will be used for communication on site to alert personnel of the occurrence of a pollution incident. It is a fast and effective way to communicate so that personnel can ensure their personal safety.

8.2.2 Notification of authorities Immediately after Alkane is aware of a pollution incident a “PHGM Key Contact” will notify all authorities listed in section 8.2 of this plan.

The following protocol will be followed for notification of pollution incidents:

8.2.2.1 Protocol 1. Call 000 if the incident presents an immediate threat to human health or property. Fire and

Rescue NSW, NSW Police and NSW Ambulance Service. These are the first responders and responsible for controlling and containing incidents.

2. If the incident does not require an initial combat agency, or once the 000 call has been made,

notify the relevant authorities in the following order:

a. The EPA b. NSW Health (via the local Hospital) c. WorkCover NSW d. Parkes Shire Council e. Fire and Rescue NSW

The information that is required to be notified is as follows:

a) The time, date, nature, duration and location of the incident,

b) The location where pollution is occurring or likely to occur,

c) The nature, the estimated quantity or volume and the concentration of any pollutants involved, if known,

d) The circumstances in which the incident occurred (including the cause of the incident),

e) The action taken and proposed to be taken to deal with the incident and any resulting pollution or threatening pollution, if known,

f) Any other information prescribed by regulations.

Notification is required immediately. Any information required that is not known at the time of the incident can be notified when it becomes known.

8.2.3 Consultation of the MSDS If the pollution incident involves the use of a product for which an MSDS is available then upon notification of a pollution incident, the MSDS shall be consulted to obtain information to help in the management of



the incident which may include recovering the product and performing the clean-up. In certain instances, specialised outside help may be needed. The MSDS will also provide information on the appropriate PPE to be worn if it is decided to approach the polluted area.

8.2.4 Notification of Neighbours Neighbours will be contacted directly via the phone in the event of a pollution incident if there is risk of harm to their safety.

8.3 ACTIONS FOLLOWING A POLLUTION INCIDENT

8.3.1 Clean up and Recovery Following a pollution incident key personnel will develop a clean-up and recovery plan. It may be possible to undertake this using resources on site or depending on the situation may require the engagement of emergency services or professional clean-up crews with breathing apparatus and sophisticated recovery plant.

8.3.2 Incident Report Following a pollution incident Alkane will undertake a comprehensive investigation of the event and complete an Incident Report (template in Appendix 2). Within 7 days of the incident this report will be issued to authorities.

9. C O N TAC T D E TAI L S

9.1 PHGM KEY CONTACTS The people listed in Table 5 are responsible for activating this plan, are authorised to notify the appropriate regulatory authorities and are responsible for managing the response to a pollution incident is accordance with this plan.

Table 5 – Peak Hill Gold Mine Key Contacts

KEY CONTACT POSITION CONTACT DETAILS (24Hrs)

Michael Sutherland General Manager NSW 0427 691 733

Ken Robinson PHGM Site Superintendent 0428 836 587

9.2 APPROPRIATE REGULATORY AUTHORITIES The table below provides contact information for the appropriate regulatory authorities. All Appropriate Regulatory Authorities are to be contacted in the event of a pollution incident.

Table 6 – Appropriate Regulatory Authorities - Contact Details

Regulatory Authority Key Contact Contact Details

NSW Office of Environment and Heritage

Bradley Tanswell

(Dubbo Office) EPA Pollution Line 131 555



Regulatory Authority Key Contact Contact Details

(Department of the Environment Protection Authority)

WorkCover NSW 131 050

NSW Ministry of Health Public Health Unit – Environmental Health Officer - Dubbo Office

02 6841 5569

Parkes Shire Council Kent Boyd – General Manager

2 Cecile Street, Parkes NSW 2870

(02) 6861 2333

Fire, Police, Ambulance 000

9.3 COMMUNICATING WITH NEIGHBOURS Table 7 provides details of the closest neighbours to the site and their distance from the site.

Table 7 – Neighbours contact details

Neighbour Distance Key Contact Contact Details

NORTH

“Lyndavale” Next door to sediment pond discharge points

Mr Don Stanford 02 6869 1311,

0424 077 354

The northeast and northwest sediment ponds discharge into neighbouring farmland (“Lyndavale”) contour banks and dams

Other key neighbours surrounding the PHGM are described below and will be contacted if the pollution incident is a threat to them.

• The Newell Highway is situated within 500m of the Mining Leases at PHGM;

Roads and Maritime Services – Paul Maloney, Traffic Operations Manager Western Region T 02 6861 1686 F 02 6861 1415 M 0428 785 661 51-55 Currajong St Parkes NSW 2870

• Burrabadine Creek, an ephemeral creek 3km north of PHGM which drains into the Bogan River;

NSW Office of Water, Tim Baker (Dubbo Office), Senior Planning & Assessment Coordinator Major Projects, Mines and Assessment, (02) 6841 7403 M 0428 162 097

10. T R AI N I N G The following training will be undertaken to ensure that the PIRMP is well understood and that all staff (Site Superintendent) are familiar with the requirements of the plan and the key steps to manage a pollution incident:



• Persons identified as Alkane Key Personnel will attend Tool Box meetings on the requirements of

the PIRMP.

11. AC C E S S TO TH E P I RM P This plan will be kept at the PHGM site office (on the premise to which the EPL relates). The PIRMP will also be kept on the project server at: P:\Alkane\01 Admin (Technical Filing)\120 – Environment\PIRMP The PIRMP is also available on the project website: www.alkane.com.au

12. T E S TI NG O F TH E P I RM P The PIRMP will be tested annually. Testing of the PIRMP will include:

• A desktop review of the plan to ensure that the information is accurate and up to date. • A drill exercise to simulate one of the potential incidents identified within the risk assessment in

Appendix 1. As it is a requirement of the legislation, this plan will also be tested within one month of any pollution incident occurring on site.

Table 8 - Register for Testing the PIRMP

Date of Test People Involved Comments/Outcomes

14 September 2015 Ken Robinson and Stew Lamond

Exercise only - Use of trailing firefighting unit to extinguish a small fire

19 July 2016 Ken Robinson sandbagged NE sediment overflow as pond was rising from significant rainfall event

Exercise only – to establish effective increase in capacity of pond to contain pollution on site

14 June 2017 Mike Sutherland and Ken Robinson

Exercise only – safe access and egress of a light truck from Proprietary pit

In 2014 the NSW EPA introduced a risk-based licencing system. A risk assessment of the premises was undertaken by EPA officers in consultation with the licence holder (Alkane) in December 2014.

http://www.alkane.com.au/



Appendix 1 Pollution Incident Risk Assessment Risk Assessment Risk Rating Matrix

Likelihood Consequences Insignificant 1 Minor 2 Moderate 3 Major 4 Catastrophic 5

A (Almost Certain) H H E E E B (Likely) M H H E E C (Possible) L M H E E D (Unlikely) L L M H E E (Rare) L L M H H

Consequence of Occurrence: 1 = Insignificant; 2 = Minor; 3 = Moderate; 4 = Major; 5 = Catastrophic Likelihood of Occurrence: A = Almost Certain; B = Likely; C = Possible; D = Unlikely; E = Rare Risk Rating: E = Extreme; H = High; M = Moderate; L = Low

Risk Source Unmitigated Risk Ranking

Mitigation Consequence of Occurrence if Mitigated

Likelihood of Occurrence if mitigated

Residual Risk Rating

Pollution of surface water due to AMD

3C=H Soil treatment with lime and topsoil to affected outbreaks, NE sediment pond

2 3 M

Initiation of fire on the mine site and spread to adjoining properties

3C=H Fire breaks, fire fighting equipment on site 2 3 M

Sewage Spill causes impact to human health, surface water or ground contamination

2D=L Use a licensed contractor to service toilets, do not locate toilets near surface water, empty toilets regularly

2 2 L

Note: Incidents involving light and noise are not defined as “Pollution Incidents” by the EPA.



Appendix 2 Incident Report – Template

Incident Report

Date Report Raised

Raised By

Date of Incident

Description of Incident

Corrective Action Completed By Due Date

Preventative action Completed By Due Date

Incident Report Closed out By: Signed by Issuer:

Comments: Date

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